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ELECTRONICALLY FILED
Law Office Of Superior Court of California
MICHAEL P. RING County of Santa Barbara
AND ASSOCIATES
Michael P. Ring, State Bar #95922 Darrel E. Parker, Executive Officer
Iris L. M. Ring, State Bar #298179 8/26/2016 3:12:37 PM
1234 Santa Barbara Street By: Narzralli Baksh, Deputy
Santa Barbara, CA 93101
(805) 564-2333
ATTORNEYS FOR PATSY MOLER
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SANTA BARBARA
ANACAPA DIVISION
PATSY MOLER, Case No. 1417847
Plaintiff, PATSY MOLER'S REQUESTED
SPECIAL VERDICT FORM
v.
TRIAL DATE: 7/13/16
Chris Hulme, individually and dba TIME: 11:30 A.M.
Clearview Industries, Inc., Jennifer Hulme, DEPT: SB1
individually and dba Clearview Industries,
Inc., and DOES 1 through 10, inclusive
Defendants. (Assigned to Hon. James E. Herman)
And Related Cross-Actions
Patsy Moler submits the following Special Verdict Form.
Respectfully submitted,
LAW OFFICE OF MICHAEL P. RING & ASSOC.
Dated: August 26, 2016 B
MICHAE P. RING
ATTO' EYS FOR PLA IFF
-1-
PATSY MOLER'S REQUESTED SPECIAL VERDICT FORM
We the jury in the above entitled action, find the following special verdict on the following
questions submitted to us:
1. Did Patsy Moler enter into a contract with any defendant?
Yes No
If your answer to question 1 is yes, then answer question 2. If you answered no, then answer
question 9.
2. Which of the defendant(s) entered into a contract with Patsy Moler?
Clearview Industries, Inc. Yes No
Chris Hulme Yes No
Jennifer Hulme Yes No
Answer question 3.
3. Did any defendant fail to do something that the contract required him/her/it to do or
do something that the contract prohibited him/her/it from doing?
Yes No
If your answer to question 3 is yes, then answer question 4. If you answered no, then answer
question 9.
4. Which of the defendant(s) failed to perform something that the contract required or
did something that the contract prohibited him/her/it from doing?
Clearview Industries, Inc. Yes No
Chris 1-lulme Yes No
Jennifer Hulme Yes No
5. Was Patsy Moler harmed by any defendants' breach of contract?
Yes No
If your answer to question 5 is yes, then answer question 6. If you answered no, then answer
question 7.
-2-
PATSY MOLER'S REQUESTED SPECIAL VERDICT FORM
6. What are Patsy Moler's damages?
a. Past loss:
b. Future loss:
TOTAL $
Answer question 7.
7. Did any defendant make a false representation to Patsy Moler?
Yes No
If your answer to question 7 is yes, then answer question 8. If you answered no, then answer
question 15.
8. Which of the defendant(s) made a false representation(s) to Patsy Moler?
Clearview Industries, Inc. Yes No
Chris Hulme Yes No
Jennifer Hulme Yes No
Answer question 9.
9. Did any of the defendant(s) know that the representation(s) was/were false, or did
any of the defendant(s) make the representation(s) recklessly and without regard for its truth?
Yes No
If your answer to question 9 is yes, then answer question 10. If you answered no, then
answer question 15.
10. Which of the defendant(s) knew that the representation(s) was/were false, or made
the representation(s) recklessly and without regard for its truth?
Clearview Industries, Inc. Yes No
Chris Hulme Yes No
Jennifer Hulme Yes No
-3-
PATSY MOLER'S REQUESTED SPECIAL VERDICT FORM
Answer question 11.
11. Did any defendant intend that Patsy Moler rely on the representation(s)?
Yes No
If your answer to question 11 is yes, then answer question 12. If you answered no, then
answer question 15.
12. Which of the defendant(s) intend that Patsy Moler rely on the representation(s)?
Clearview Industries, Inc. Yes No
Chris Hulme Yes No
Jennifer Hulme Yes No
Answer question 13.
13. Did Patsy Moler reasonably rely on the representation(s)?
Yes No
If your answer to question 13 is yes, then answer question 14. If you answered no, then
answer question 15.
14. Was Patsy Moler's reliance on any defendant's representation(s) a substantial factor
in causing harm to Patsy Moler?
Yes No
Answer question 15.
15. Did any defendant intentionally fail to disclose facts that Patsy Moler did not know
and could not reasonably have discovered?
Yes No
If your answer to question 15 is yes, then answer question 16. If you answered no, then
answer question 20.
16. Which of the defendant(s) intentionally failed to disclose facts that Patsy Moler did
not know and could not reasonably have discovered?
-4-
PATSY MOLER'S REQUESTED SPECIAL VERDICT FORM
Clearview Industries, Inc. Yes No
Chris Hulme Yes No
Jennifer Hulme Yes No
Answer question 17.
17. Did any defendant intend to deceive Patsy Moler by concealing the fact(s)?
Yes No
If your answer to question 17 is yes, then answer question 18. If you answered no, then
answer question
18. Had the omitted information been disclosed, would Patsy Moler reasonably have
behaved differently?
Yes No
If your answer to question 18 is yes, then answer question 19. If you answered no, then
answer question 20.
19. Was any defendant's concealment a substantial factor in causing harm to Patsy Moler?
Yes No
If either your answer to question 14 or question 19 is yes, then answer question 20. If you
answered both question 14 and question 19 no, then answer question 21.
20. What are Patsy Moler's damages from either the misrepresentation(s) or
concealment(s) by any defendant?
a. Past economic loss
b. Future economic loss
c. Past noneconomic loss, including mental suffering:
-5-
PATSY MOLER'S REQUESTED SPECIAL VERDICT FORM
d. Future noneconomic loss, including mental suffering:
TOTAL
21. Did any defendant perform acts that require a California Contractor's license when
that defendant did not have the required license?
Yes No
If your answer to question 21 is yes, then answer question 22. If you answered no, then
answer question 26.
22. Which of the defendant(s) performed acts that require a California Contractor's
license when that defendant did not have the required license?
Clearview Industries, Inc. Yes No
Chris Hulme Yes No
Jennifer Hulme Yes No
Answer question 23.
23. Was any defendant paid any money for work performed that required a California
Contractor's license when that defendant did not have the required license?
Yes No
If your answer to question 25 is yes, then answer question 26. If you answered no, then
answer question 26.
24. Which of the defendant(s) performed acts that required a California Contractor's
license when that defendant did not have the required license?
Clearview Industries, Inc. Yes No
Chris Hulme Yes No
Jennifer Hulme Yes No
Answer question 27.
-6-
PATSY MOLER'S REQUESTED SPECIAL VERDICT FORM
25. How much money was any defendant paid for work performed that required a
California Contractor's license when that defendant did not have the required license?
Answer question 28.
26. Did any defendant engage in the conduct with malice, oppression, or fraud?
Yes No
If your answer to question 28 is yes, then answer question 29. If you answered no, stop
here, answer no further questions, and have the presiding juror sign and date this form.
27. Which of the defendant(s) engaged in the conduct with malice, oppression, or fraud?
Clearview Industries, Inc. Yes No
Chris Hulme Yes No
Jennifer Hulme Yes No
Have the presiding juror sign and date this form.
Signed:
Presiding Juror
Dated:
After this verdict form has been signed, notify the bailiff that you are ready to present your
verdict in the courtroom.
-7-
PATSY MOLER'S REQUESTED SPECIAL VERDICT FORM
1 PROOF OF SERVICE
STATE OF CALIFORNIA, COUNTY OF SANTA BARBARA
2
3 I am employed in the County of Santa Barbara, State of California. I am over the age of 18
and not a party to the within action; my business address is 1234 Santa Barbara Street, Santa Barbara,
4 California, 93101.
5 On August 26, 2016, I served the foregoing document described as PATSY MOLER'S
REQUESTED VERDICT FORM on the interested parties in this action
6
XX by placing the original XX a true copy thereof addressed as follows:
7 JEFFREY M. BENNION BRIAN K. FINDLEY
2869 INDIA ST MULLIGAN, BANHAM & FINDLEY
8 SAN DIEGO, CA 92103 2442 Fourth Avenue, Suite 100
9 San Diego, CA 92101
10
(BY FEDERAL EXPRESS OVERNIGHT DELIVERY) I caused such documents to be
11 picked up by Federal Express at 1234 Santa Barbara St., Santa Barbara, California, 93101, in a box
designated by Federal Express for overnight delivery, with delivery fees provided for, addressed to
12 the person on whom it is to be served.
13 (BY PERSONAL SERVICE) I caused such envelope to be delivered by hand to the
addressee at 1100 ANACAPA STREET, SANTA BARBARA CA
14
15 XX (BY ELECTRONIC SERVICE) the electronic address where I served this is
iefMibennionlaw.com, findley@janmulligan.com
16
(BY PLACING FOR COLLECTION AND MAILING) I placed the above-mentioned
17 document(s) in sealed envelope(s) addressed as set forth above, and placed the envelope(s) for
collection and mailing following ordinary business practices. I am readily familiar with the film's
18 practice for collection and processing of correspondence for mailing with the United States Postal
19 Service. Under that practice it would be deposited with the U.S. Postal Service on that same day
with postage thereon fully prepaid at 1234 Santa Barbara Street, Santa Barbara, CA 93101 in the
20 ordinary course of business.
21 XX (STATE) I declare under penalty of perjury under the laws of the State of California that the
above is true and correct.
22
23 Executed on August 26, 2016, at Santa Barbara, California.
24
MICHAEL P. RING
25 Type or Print Name
26
27
28
1
PROOF OF SERVICE
Preview
ELECTRONICALLY FILED Law Office Of Superior Court of California MICHAEL P. RING County of Santa Barbara AND ASSOCIATES Michael P. Ring, State Bar #95922 Darrel E. Parker, Executive Officer Iris L. M. Ring, State Bar #298179 8/26/2016 3:12:37 PM 1234 Santa Barbara Street By: Narzralli Baksh, Deputy Santa Barbara, CA 93101 (805) 564-2333 ATTORNEYS FOR PATSY MOLER SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SANTA BARBARA ANACAPA DIVISION PATSY MOLER, Case No. 1417847 Plaintiff, PATSY MOLER'S REQUESTED SPECIAL VERDICT FORM v. TRIAL DATE: 7/13/16 Chris Hulme, individually and dba TIME: 11:30 A.M. Clearview Industries, Inc., Jennifer Hulme, DEPT: SB1 individually and dba Clearview Industries, Inc., and DOES 1 through 10, inclusive Defendants. (Assigned to Hon. James E. Herman) And Related Cross-Actions Patsy Moler submits the following Special Verdict Form. Respectfully submitted, LAW OFFICE OF MICHAEL P. RING & ASSOC. Dated: August 26, 2016 B MICHAE P. RING ATTO' EYS FOR PLA IFF -1- PATSY MOLER'S REQUESTED SPECIAL VERDICT FORM We the jury in the above entitled action, find the following special verdict on the following questions submitted to us: 1. Did Patsy Moler enter into a contract with any defendant? Yes No If your answer to question 1 is yes, then answer question 2. If you answered no, then answer question 9. 2. Which of the defendant(s) entered into a contract with Patsy Moler? Clearview Industries, Inc. Yes No Chris Hulme Yes No Jennifer Hulme Yes No Answer question 3. 3. Did any defendant fail to do something that the contract required him/her/it to do or do something that the contract prohibited him/her/it from doing? Yes No If your answer to question 3 is yes, then answer question 4. If you answered no, then answer question 9. 4. Which of the defendant(s) failed to perform something that the contract required or did something that the contract prohibited him/her/it from doing? Clearview Industries, Inc. Yes No Chris 1-lulme Yes No Jennifer Hulme Yes No 5. Was Patsy Moler harmed by any defendants' breach of contract? Yes No If your answer to question 5 is yes, then answer question 6. If you answered no, then answer question 7. -2- PATSY MOLER'S REQUESTED SPECIAL VERDICT FORM 6. What are Patsy Moler's damages? a. Past loss: b. Future loss: TOTAL $ Answer question 7. 7. Did any defendant make a false representation to Patsy Moler? Yes No If your answer to question 7 is yes, then answer question 8. If you answered no, then answer question 15. 8. Which of the defendant(s) made a false representation(s) to Patsy Moler? Clearview Industries, Inc. Yes No Chris Hulme Yes No Jennifer Hulme Yes No Answer question 9. 9. Did any of the defendant(s) know that the representation(s) was/were false, or did any of the defendant(s) make the representation(s) recklessly and without regard for its truth? Yes No If your answer to question 9 is yes, then answer question 10. If you answered no, then answer question 15. 10. Which of the defendant(s) knew that the representation(s) was/were false, or made the representation(s) recklessly and without regard for its truth? Clearview Industries, Inc. Yes No Chris Hulme Yes No Jennifer Hulme Yes No -3- PATSY MOLER'S REQUESTED SPECIAL VERDICT FORM Answer question 11. 11. Did any defendant intend that Patsy Moler rely on the representation(s)? Yes No If your answer to question 11 is yes, then answer question 12. If you answered no, then answer question 15. 12. Which of the defendant(s) intend that Patsy Moler rely on the representation(s)? Clearview Industries, Inc. Yes No Chris Hulme Yes No Jennifer Hulme Yes No Answer question 13. 13. Did Patsy Moler reasonably rely on the representation(s)? Yes No If your answer to question 13 is yes, then answer question 14. If you answered no, then answer question 15. 14. Was Patsy Moler's reliance on any defendant's representation(s) a substantial factor in causing harm to Patsy Moler? Yes No Answer question 15. 15. Did any defendant intentionally fail to disclose facts that Patsy Moler did not know and could not reasonably have discovered? Yes No If your answer to question 15 is yes, then answer question 16. If you answered no, then answer question 20. 16. Which of the defendant(s) intentionally failed to disclose facts that Patsy Moler did not know and could not reasonably have discovered? -4- PATSY MOLER'S REQUESTED SPECIAL VERDICT FORM Clearview Industries, Inc. Yes No Chris Hulme Yes No Jennifer Hulme Yes No Answer question 17. 17. Did any defendant intend to deceive Patsy Moler by concealing the fact(s)? Yes No If your answer to question 17 is yes, then answer question 18. If you answered no, then answer question 18. Had the omitted information been disclosed, would Patsy Moler reasonably have behaved differently? Yes No If your answer to question 18 is yes, then answer question 19. If you answered no, then answer question 20. 19. Was any defendant's concealment a substantial factor in causing harm to Patsy Moler? Yes No If either your answer to question 14 or question 19 is yes, then answer question 20. If you answered both question 14 and question 19 no, then answer question 21. 20. What are Patsy Moler's damages from either the misrepresentation(s) or concealment(s) by any defendant? a. Past economic loss b. Future economic loss c. Past noneconomic loss, including mental suffering: -5- PATSY MOLER'S REQUESTED SPECIAL VERDICT FORM d. Future noneconomic loss, including mental suffering: TOTAL 21. Did any defendant perform acts that require a California Contractor's license when that defendant did not have the required license? Yes No If your answer to question 21 is yes, then answer question 22. If you answered no, then answer question 26. 22. Which of the defendant(s) performed acts that require a California Contractor's license when that defendant did not have the required license? Clearview Industries, Inc. Yes No Chris Hulme Yes No Jennifer Hulme Yes No Answer question 23. 23. Was any defendant paid any money for work performed that required a California Contractor's license when that defendant did not have the required license? Yes No If your answer to question 25 is yes, then answer question 26. If you answered no, then answer question 26. 24. Which of the defendant(s) performed acts that required a California Contractor's license when that defendant did not have the required license? Clearview Industries, Inc. Yes No Chris Hulme Yes No Jennifer Hulme Yes No Answer question 27. -6- PATSY MOLER'S REQUESTED SPECIAL VERDICT FORM 25. How much money was any defendant paid for work performed that required a California Contractor's license when that defendant did not have the required license? Answer question 28. 26. Did any defendant engage in the conduct with malice, oppression, or fraud? Yes No If your answer to question 28 is yes, then answer question 29. If you answered no, stop here, answer no further questions, and have the presiding juror sign and date this form. 27. Which of the defendant(s) engaged in the conduct with malice, oppression, or fraud? Clearview Industries, Inc. Yes No Chris Hulme Yes No Jennifer Hulme Yes No Have the presiding juror sign and date this form. Signed: Presiding Juror Dated: After this verdict form has been signed, notify the bailiff that you are ready to present your verdict in the courtroom. -7- PATSY MOLER'S REQUESTED SPECIAL VERDICT FORM 1 PROOF OF SERVICE STATE OF CALIFORNIA, COUNTY OF SANTA BARBARA 2 3 I am employed in the County of Santa Barbara, State of California. I am over the age of 18 and not a party to the within action; my business address is 1234 Santa Barbara Street, Santa Barbara, 4 California, 93101. 5 On August 26, 2016, I served the foregoing document described as PATSY MOLER'S REQUESTED VERDICT FORM on the interested parties in this action 6 XX by placing the original XX a true copy thereof addressed as follows: 7 JEFFREY M. BENNION BRIAN K. FINDLEY 2869 INDIA ST MULLIGAN, BANHAM & FINDLEY 8 SAN DIEGO, CA 92103 2442 Fourth Avenue, Suite 100 9 San Diego, CA 92101 10 (BY FEDERAL EXPRESS OVERNIGHT DELIVERY) I caused such documents to be 11 picked up by Federal Express at 1234 Santa Barbara St., Santa Barbara, California, 93101, in a box designated by Federal Express for overnight delivery, with delivery fees provided for, addressed to 12 the person on whom it is to be served. 13 (BY PERSONAL SERVICE) I caused such envelope to be delivered by hand to the addressee at 1100 ANACAPA STREET, SANTA BARBARA CA 14 15 XX (BY ELECTRONIC SERVICE) the electronic address where I served this is iefMibennionlaw.com, findley@janmulligan.com 16 (BY PLACING FOR COLLECTION AND MAILING) I placed the above-mentioned 17 document(s) in sealed envelope(s) addressed as set forth above, and placed the envelope(s) for collection and mailing following ordinary business practices. I am readily familiar with the film's 18 practice for collection and processing of correspondence for mailing with the United States Postal 19 Service. Under that practice it would be deposited with the U.S. Postal Service on that same day with postage thereon fully prepaid at 1234 Santa Barbara Street, Santa Barbara, CA 93101 in the 20 ordinary course of business. 21 XX (STATE) I declare under penalty of perjury under the laws of the State of California that the above is true and correct. 22 23 Executed on August 26, 2016, at Santa Barbara, California. 24 MICHAEL P. RING 25 Type or Print Name 26 27 28 1 PROOF OF SERVICE